At the dawn of the 20th century, Harrisburg and other Pennsylvania cities were plagued by foul air, unpaved and garbage strewn streets, open sewers, polluted water, and a host of other ills. Reflecting the widespread belief that an unregulated economy brought the greatest good to the greatest numbers, Pennsylvania's courts pushed private enterprises' pollution of the air and water into the category of "trivial harm" and for decades rarely punished polluters.